Built to Last

On a recent trip to Rome for a conference my sightseeing
partner noted: “These people know how to build things that last.”

My colleague Mark Alavosius and I were there for an exciting
reason, but one that has me perplexed. This
will take some explaining.

Background: In most of Europe, companies get
“certified” in a number of ways. The best
known is the ISO9000 criteria where independent auditors evaluate process and
policy documents and provide their “stamp” of Certification. Companies enjoy preferred status as suppliers
and service providers because of their assumed quality assurance from the Certification. Many companies in the United States pursue
these Certifications as well.

When it comes to safety, Certifications are not voluntary in
many European countries. In Italy, there
are laws requiring Certification in a number of safety areas. These Certifications, in contrast to ISO9000,
are not optional. When a safety incident
occurs and the company contacts their insurance providers to cover medical and
workers comp, the insurance provider can ask for their Certifications. If the Certifications are not in order then
the insurance provider can deny payment. Hence there is a big incentive for companies
to comply with safety Certifications.

The government writes the laws, its ministries convert them to
policy, Certification entities convert them into strict criteria, and Certification
auditor consultants offer Certifications.
Companies put their safety programs in place and seek Certification from
these auditors to complete the bureaucratic process.

Opportunity:
Behavior-Based Safety (BBS) in Italy has enjoyed a number of successes
and has been gaining the attention of people involved in the Certification
process. Because of this, a number of
scientists have been assembled to help develop a Certification program in BBS. This involved Behavior Analytic (the
scientists behind BBS) non-profits in Italy (Association for the Advancement of
Radical Behavior Analysis: AARBA; www.aarba.eu) and in the US (Cambridge Center
for Behavioral Studies: CCBS; www.behavior.org). Mark and I are commissioners for CCBS and
have experience with a voluntary Behavioral Safety Accreditation program that
CCBS offers.

So, how to create a National Certification Program in
BBS? Quite a challenge! We started with defining what BBS is; that
took a year. You can check out our
definition of BBS on our website (www.behavior.org)
after August 15th. We’d love to hear
your comments.

The current challenge, however, is to set the criteria for Certification. What will the auditors look for? As Behavior Analysts who research BBS we look
for RESULTS. Therefore, we were not
satisfied with the normal European Certification only looking for documentation
that a process is in place. For a
company to claim Certification in BBS, after an initial start-up phase, we
would want to see a reduction of injuries.
After all, that’s the point right?

So we crafted three levels of Certification based on the
common maturity of successful BBS programs:

Stage 1: A
company designs its BBS process and stage 1 Certification is granted if these
documents meet the BBS definition.

Stage 2:
The Company has implemented BBS and must show evidence of successful
implementation to be granted Stage 2 Certification (up to one year later).

Stage 3:
The Company has a mature BBS process and can receive Stage 3 Certification
after demonstrating reductions in injury rates (up to 3-5 years).

The QUESTIONS:

Setting criteria for Stage 1 and Stage 3 are relatively straightforward. Stage 1 involves a checklist of BBS process
parts that must be in the design of a company’s BBS program. Stage 3 looks at outcome (injury) data
seeking improvement. Obviously there are
some statistical issues to work out in Stage 3 but this is doable.

Stage 2 criteria begs a fascinating question that I’ve
encountered many times by company leaders and safety managers after
implementing a new BBS: How do you show a
successful implementation of BBS… before the lagging indicators of injury
reduction catch up?

There are a ton of issues here: How many observers are
needed? How many observations should be
done? What is useful feedback? Could you track actionable trends from the
resulting data?

I would appreciate if you sent me YOUR potential solution to
this question (TimLudwig@Safety-Doc.com). I’ll post them on the website and forward
them to the certification task force.

THE PERPLEXITY

It is Stage 2 that also has me perplexed
because we will be establishing rules for the Italian Certification auditors.
This, of course will lead to compliance of these rules in companies seeking to
be Certified. We are talking about
government laws… carried out by these auditors… that can impact companies
substantially.

Consider a typical leading indicator of BBS success. Within a BBS process, observations are
conducted. Therefore, the number of
observations conducted is a good indicator that the process is being done, that
people are participating, and that the data can be analyzed for trends.

Indeed, research shows that increases in observations are
highly correlated with reductions in injuries over time. Observations Lead – Injury reduction
Lags. Stage 2 leading to Stage 3.

Case closed: The Certification should simply require a
certain number of observations to be done… over a certain period of time, based
on the number of workers, hours worked, etc.

CASE CLOSED?

Consider these vexing questions about mandated
observations: Will the observations be
done according to the BBS design? Will
they identify areas of risk with high quality?
Will the observations be associated with conversations with the employee
about the risks? Will the observations be
done at all???

Think about it… if a specified observation count were required
to pass Certification… what will happen?
My guess is that that observation count will be attained by some method,
any method. Mandating observations lead
to LOW QUALITY observations… in the worst cases mandates lead to false
observations.

Every time I’ve been asked to help “fix” a “broken” BBS
program I’ve seen mandated observation quotas.
Employee incentives for doing observation can lead to the same
problem. In these cases, sites typically
boast large numbers of observations but these “observations” have had little
impact on injury rates.

I see the need for clear based criteria in Certification
showing that BBS is in place and is working correctly. I think I’m leaning toward the observations
count. However, I’d pair it with two
other criteria to ensure that data are being used to guide decisions and
actions that lead to safety results.

b)Action plans that successfully addressed the
risks and increased the percentage of safe behaviors in that area.

So what would you list as criteria to demonstrate that your
BBS process has been implemented correctly?
I’d love to hear your take on this challenge (TimLudwig@Safety-Doc.com).

I’m generally skeptical of certification– It tends to lead
to bureaucracies that self-sustain and grow with limited value. However, this BBS Certification can
positively impact the lives of millions of Italians…. if we do it right.